Saturday, October 13, 2007

There's more than a few issues and challenges open for consideration and debate when it comes to allowing more and more "open access" and license-free use of the radio spectrum as the authors of this 2005 white paper attempt to point out....

The open access, unlicensed or spectrum commons approach to managing shared access to RF spectrum offers many attractive benefits, especially when implemented in conjunction with and as a complement to a regime of market-based, flexible use, tradable licensed spectrum.

However, as a number of critics have pointed out, implementing the unlicensed model poses difficult challenges that have not been well-addressed yet by commons advocates.

A successful spectrum commons will not be unregulated, but it also need not be command & control by another name. This paper seeks to address some of the implementation challenges associated with managing a spectrum commons. We focus on the minimal set of features that we believe a suitable management protocol, etiquette, or framework for a spectrum commons will need to incorporate.

This includes: (1) No transmit only devices; (2) Power restrictions; (3) Common channel signaling; (4) Mechanism for handling congestion and allocating resources among users/uses in times of congestion; (5) Mechanism to support enforcement (e.g., established procedures to verify protocol is in conformance); (6) Mechanism to support reversibility of policy; and (7) Protection for privacy and security.

We explain why each is necessary, examine their implications for current policy, and suggest ways in which they might be implemented. We present a framework that suggests a set of design principles for the protocols that will govern a successful commons management regime. Our design rules lead us to conclude that the appropriate Protocols for a Commons will need to be more liquid than in the past: (1) Market-based instead of C&C; (2) Decentralized/distributed; and, (3) Adaptive and flexible (Anonymous, distributed, decentralized, and locally responsive).

Offered as suggested background reading and insight in light of the big push for these by the TV "white spaces" proponents, the Cognitive Radio/SDR folks, and the Google's, Intel's, and Microsoft's of the new wireless world.

"Another technology was said to overcome key barriers between the voter and the candidate: the barriers of distance, of time, of inertia, and of crowd psychology. It brought to the physically remote voter a type of first-hand information he had never had before.

There was great excitement. Would this new technology prick into quicker, more coherent action our unwieldy democratic giant? Or with its shining novelty would its seeming power too be gone? What were the inherent political potentialities of this new technology? Aside from the immense publicity value which its newness gave it, what could it actually effect in a presidential election?

The new technology was remarkable. It had found a way to dispense with political middlemen. In a fashion it had restored the demos upon which republican government is founded. No candidate would be able to stand up to it who was unprepared to enlighten the electorate. It potentially gave to every member of the electorate the possibility of a direct reaction to the candidates themselves. It reproduced to some degree, for the first time in the United States, the conditions of the Athenian democracy where every voter, for himself, could hear and judge the candidates.

The year was 1924: “…America finds herself this year in the act of virtually choosing her chief executive by an instrument that was up to a brief two years ago generally considered a freakish fad.”

You'll have to visit her site for the balance of her post, but, she's absolutely correct - radio or RF (now commonly labeled "wireless") and Internet technology has and will continue to transform virtually every aspect of our lives and the world in which we live.

Monday, October 8, 2007

"As a regulatory agency, FCC is routinely lobbied by stakeholders with a vested interest in the issues FCC regulates. It is critical that FCC maintain an environment in which all stakeholders have an equal opportunity to participate in the rulemaking process AND that the process is perceived as fair and transparent.

Situations where some, but not all, stakeholders know what FCC is considering for an upcoming vote undermine the fairness and transparency of the process and constitute a violation of FCC's rules.

Since the success of lobbying for a particular issue can be highly dependent on whether an issue is being actively considered, FCC staff who disclose nonpublic information about when an issue will be considered could be providing an advantage to some stakeholders, allowing them to time their lobbying efforts to maximize their impact. As a result, FCC may not hear from all sides of the issue during an important part of the rulemaking process. This imbalance of information is not the intended result of the Communications Act, and it runs contrary to the principles of transparency and equal opportunity for participation established by law and to FCC's own rules that govern rulemaking."

The GAO report really isn't much of a surprise, at least to those of us who have been involved in the communications industry for any length of time; it's been quite evident for many years that the lobbying process itself has been more-than-a-little slanted in favor of large corporate entities (wireless and wireline telecommunication incumbents, media, and the broadcast folks come to mind here)......this report seems to "officially" validate that evidence albeit the facts are based on just a very small sample of the FCC's many proceedings.

Perhaps the GAO auditors should return and dig a bit deeper; so far, they've only managed to scratch the surface of what many believe may be a larger problem within this agency. Oh, by the way, the FCC declined to comment or refute the GAO's report.

How timely. It's only been 3 years since the NTIA's original Phase 1 report which warned of the potential for harmful interference to LICENSED users that very well could (and have) resulted from the deployment of UN-licensed, Part 15 BPL technology in that portion of the spectrum. The Phase 2 BPL report was supposed to have been issued several months later, but was never made public. One excuse offered for the delay was that there were only 2 report writers within the NTIA to author the Phase 2 report; however, in the opinion of many in the know, the completion and release of the report was deliberately withheld for strategic political reasons.

It's interesting to note that during this 3 year gap, the FCC managed to rush/push/shove their BPL Rules through the regulatory system despite the well-presented and documented concerns and objections of many users of this spectrum. (See the Comments and Reply Comments in the FCC's ET Docket 04-37 for more background and insight on this proceeding.)

It's also telling that a recent report from NATO (9 MB file) seems to contradict some of the findings of the Phase 2 BPL report. I wonder how often certain elements of this report have been "revised" or glossed over in the last 3 years in an attempt to soften the impact of this "spectrum polluting" technology and promote the well-intended but mis-guided notion of BPL providing the so-called "3rd pipe" for wireless broadband access in rural areas?

Finally, isn't it odd that the release of the Phase 2 report comes on the same day the the FCC's own Inspector General released a report that claims the FCC did not withhold similar reports that were not entirely favorable to its policy positions? (Why do I have my doubts?)

Me thinks there is something not quite right here, but, as a good friend often says, I could be wrong....

Thursday, October 4, 2007

A reminder for those who haven't been paying attention, may have forgotten, or, are an analog wireless die-hard in the new digital world......(believe it or not, there are still many folks out there who fall into one or more of these categories!)

The FCC has issued a public notice that as of midnight on February 18, 2008, cellular telephone companies will not be required to provide analog wireless service. While most wireless telephone users will not be affected by this transition (often called the "analog cellular sunset"), some users may be affected.

In addition, the transition could affect some wireless alarm systems and some users of OnStar's in-vehicle communications service.

In addition to the analog-to-digital transition for wireless telephone service, Congress has separately set a deadline of February 17, 2009, for completion of the transition from analog-to-digital television broadcasting. (Yep - your analog TV set has (or will) also become obsolete relatively soon)

To learn more about how the digital television transition will affect you, visit www.dtv.gov

"Spectrum management is an exercise in balancing disparate stakeholderinterests through effective user education and the enforcement of regulatory policies that reflect practical reality, political responsibility, economic common sense, and a basic understanding of the laws of physics."

About this Blog

news, insight, and opinion from a variety of both well-known and not-so-widely-known or reported industry sources, offered to provide added perspective, context, and a clearer understanding of why the wireless (RF) spectrum, technology trends, and regulatory policy should not be taken for granted - spectrum matters

About the Blogger

General Manager - Systems Group -
Quality MobileCommunications, LLC
A professional 30+ year career in the Private Wireless, Commercial LMR/SMR Two-Way Radio, and Mobile Communications segments of the wireless communications industry provides the basis for many of the thoughts and comments that may occasionally be posted here.